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HC quashed reassessment proceedings initiated beyond 4 years under s.147 on multiple grounds. Issues raised were identical to prior s.263 revision proceedings where PCIT had directed fresh assessment. Reopening on same grounds was unjustified, particularly after 4-year limitation. AO failed to specify undisclosed material facts while admitting review was based on existing records. Officer's claim of predecessor's inadvertent relief contradicted allegation of non-disclosure by assessee. Re-examination of issues already addressed in assessment order following s.263 proceedings amounts to impermissible change of opinion and review. Third proviso to s.147 bars such proceedings when matters were previously examined under s.263. Petition allowed in assessee's favor.
HC quashed reassessment proceedings initiated beyond 4 years under s.147 on multiple grounds. Issues raised were identical to prior s.263 revision proceedings where PCIT had directed fresh assessment. Reopening on same grounds was unjustified, particularly after 4-year limitation. AO failed to specify undisclosed material facts while admitting review was based on existing records. Officer's claim of predecessor's inadvertent relief contradicted allegation of non-disclosure by assessee. Re-examination of issues already addressed in assessment order following s.263 proceedings amounts to impermissible change of opinion and review. Third proviso to s.147 bars such proceedings when matters were previously examined under s.263. Petition allowed in assessee's favor.
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